Do bonuses, company cars and allowances count in the gender pay gap calculation?

Virtually every allowance falls under the concept of remuneration

Bonuses, company cars and supplements typically count in the pay gap calculation, because the directive defines remuneration very broadly. Article 3 of Directive (EU) 2023/970 defines remuneration as ordinary basic or minimum wages, plus all other benefits that a worker receives by reason of their employment — in cash or in kind, direct or indirect, fixed or variable. A bonus is variable remuneration in cash, a company car is a benefit in kind, and a supplement is an additional component added to basic salary: all three fall within that definition.

What is missing from the definition is an exception for pay components because they are irregular, governed by a separate scheme, or not a fixed part of the salary. The directive does not look at the form or name of an allowance, but at whether it stems from the employment relationship. Pure expense allowances — amounts that compensate for actual costs incurred and are therefore not a counterpart for work — are closer to the boundary of the concept, but the directive text itself does not work out that distinction with a list of what does and does not count. For the vacancy check and the calculation module on this platform, the starting point is therefore that pay components that are linked to the employment relationship are included, and that an exclusion per component must be justified separately.

Where this is stated: Articles 3 and 9 of the directive

This broad interpretation follows directly from the definition in Article 3 of Directive (EU) 2023/970. That definition forms the basis for what is included in the reporting under Article 9 of the same directive: that reporting is about pay differences between men and women, and the concept of remuneration on which those differences are calculated is therefore the broad concept from Article 3, not a more limited list of pay components.